DWEA on July 1 submitted comments regarding the U.S. Treasury Department’s Domestic Content Bonus Credit Guidance and urged the department to include certified distributed wind towers of less than 1 MW in the “safe harbor” list as “manufactured products,” similarly to tower flanges and solar trackers.
The 10 percent manufacturing bonus is both an important market stimulus and, indirectly, a significant incentive for domestic manufacturing. Treasury notices 2023-38 and 2024-41 provide clear guidance on the qualification and procedures for the bonus, and DWEA appreciates the inclusion of “safe harbors” in the notices.
DWEA highlighted to the Treasury Department that America now has small and medium wind turbine manufacturers for whom the domestic content of their manufactured components exceeds 90 percent.
The problem with the current notices, however, is the classification of towers for small and medium-sized wind energy systems as “structural” rather than as a “manufactured product.” As a result, purchasers of domestic small and medium wind turbines with domestic content exceeding 90 percent will not qualify for the ITC bonus because of their inability to find 100-percent American-made towers.
“DWEA appreciates the need to grow America’s steel and iron industries for economic and strategic reasons. But the distributed wind industry is nascent and its demand for steel is miniscule, hundreds of times smaller, compared to the annual steel demand from the multi- megawatt windfarm turbine industry with OEMs like General Electric, Vestas, and Siemens,” the association said. “This will have the real effect of slowing the growth of the distributed wind industry through the proposed tower classification, but it will not have a corresponding acceleration of steel investments and production.”
DWEA also noted the fact that Rohn Products of Peoria, Illinois, is currently the only domestic tower manufacturer for small and medium-sized wind turbines and the company is currently swamped with telecom and transmission tower orders.